Singh v. Hammond, 292 Ga. 579

Wife and Husband divorced in 2005; they have two minor children.
Final divorce decree awarded joint legal custody and gave Husband primary physical custody.
In 2009 Wife sought child support and custody modification; by 2011 parties agreed Wife had primary physical custody and Wife began receiving child support.
2011 order included a provision that Wife shall not apply for government assistance for the children as long as she receives child support.
Wife appealed the prohibition on government assistance and related financial findings; trial court’s holdings were partially reversed on appeal.
Court upheld Husband’s gross monthly income finding but reversed Wife’s gross income finding and the government-assistance prohibition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
May the trial court prohibit government assistance as a condition of child support?	Husband/Wife contend it constitutes an improper precondition for modification.	Husband argues the court can impose such a condition.	Prohibition cannot stand; invalid precondition under OCGA 19-6-15.
Was Wife's average gross monthly income correctly found to be $3,000?	Wife contends income was higher; evidence shows averages around $3,000.	Husband contends the court’s figure is correct.	Trial court’s $3,000 figure reversed; no supporting evidence for $3,000/month.
Was Husband's income correctly found to be $4,238.64 per month?	Husband provided evidence supporting the figure.	Wife argues different figure; court should credit her position.	Husband’s income of $4,238.64 per month supported and affirmed.

Frazier v. Frazier, 280 Ga. 687 (Ga. 2006) (any evidence rule; defer to trial court on credibility)
Herrin v. Herrin, 287 Ga. 427 (Ga. 2010) (appellate review standard; evidentiary support required)
Southerland v. Southerland, 278 Ga. 188 (Ga. 2004) (any evidence rule; affirm if record supports)